Skip to Main Content
FlightPushFLIGHTPUSH
Legal Interpretations

Learn

Dashboard My Courses Mastery Map Practice Flight Bag

Resources

CFR & AIM FAA Orders Handbooks & Guides Certification Standards Pilot/Controller Glossary Advisory Circulars Legal Interpretations
Safety Center
Articles Trust Center
Help Center FAQ Status
  1. Reference Library
  2. Legal Interpretations
  3. Interpretation
Loading
flightpush.co home
Loading reference

Legal Interpretations

← Previous InterpretationNext Interpretation →

Rhone 2010

1 item · About 66 KB · Auto-updates · Removed when you log out

Summary

The Question

Does an active-duty Army air traffic controller with at least 6 months of tower experience need additional experience to meet the facility rating requirements of 14 CFR 65.39?

Background

A U.S. Army specialist serving as an air traffic controller asked whether he needed six months of work experience beyond his Army controller experience before being eligible for employment at an air traffic control tower under 14 CFR 65.39.

The FAA’s Interpretation

No. Under the plain language of 14 CFR 65.39, an applicant who is a member of an Armed Force of the United States meets its practical experience requirements for a facility rating if he has satisfactorily served as an air traffic control tower operator for at least 6 months. An active-duty Army member with that service meets the requirements.

Requester
Rhone
Issued
August 6, 2010
Subject
Maintenance & Repair Stations

Regulations Cited

  • 14 CFR 65.39

Page 1

U.S. Department
of Transportation
Federal Aviation
Administration
AUG - 6 2010
Specialist Norman Rhone, USA
Dear Mr. Rhone:
Office of the Chief Counsel 800 Independence Ave., S.W.
Washington, D.C. 20591

We are in receipt of your inquiry requesting clarification of whether you need six months of work experience in addition to your experience as a controller in the U.S. Army, before being eligible for employment at an air traffic control tower under 14 C.F.R. §65.39. By the clear language of the regulation, which I have quoted below, as an active duty member of the U.S. Army with at least 6 months experience as an air traffic controller, you meet the requirements for a facility rating under §65.39. The section reads as follows:

§65.39 - Practical experience requirements: Facility rating - Each applicant for a facility rating at any air traffic control tower must have satisfactorily served- (a) As an air traffic control tower operator at that control tower without a facility rating for at least 6 months; or (b) As an air traffic control tower operator with a facility rating at a different control tower for at least 6 months before the date he applies for the rating. However, an applicant who is a member ofan Armed Force ofthe United States meets the requirements of this section {f he has satisfactorily served as an air traffic control tower operator for at least 6 months. (emphasis added) Therefore, as a member of the U.S. Army, on active duty, serving as an air traffic control tower operator for at least 6 months, you meet the experience requirements for a facility rating as specified by the rule.

We trust that the above responds to your concerns. If you need further assistance, please contact my staff at (202) 267-3072. This response was prepared by Neal O'Hara, and Attorney in the Regulations Division of the Office ofthe Chief Counsel.

Sincerely,

~p~::-';r/J-

Assistant Chief Counsel for Regulation, AGC-200

Regulations Referenced

14 CFR 65.39

Snapshot retrieved August 6, 2026.

Summary

The Question

Does an active-duty Army air traffic controller with at least 6 months of tower experience need additional experience to meet the facility rating requirements of 14 CFR 65.39?

Background

A U.S. Army specialist serving as an air traffic controller asked whether he needed six months of work experience beyond his Army controller experience before being eligible for employment at an air traffic control tower under 14 CFR 65.39.

The FAA’s Interpretation

No. Under the plain language of 14 CFR 65.39, an applicant who is a member of an Armed Force of the United States meets its practical experience requirements for a facility rating if he has satisfactorily served as an air traffic control tower operator for at least 6 months. An active-duty Army member with that service meets the requirements.

Requester
Rhone
Issued
August 6, 2010
Subject
Maintenance & Repair Stations

Regulations Cited

  • 14 CFR 65.39